Hi lads, I received a note from a friend saying that we perhaps need a bit of a heads up about the new coastal plans for ARC/Northland/Waikato.

My friend suggested we should be making submissions on possible FAD locations, if we want them for the future, as once the plans are finalised there ain't much you can do about it. With reduced fishing areas due to reserves, FAD's and artificial reefs may be useful for increasing your legal fishing areas. Sounds reasonable to me.

I'm not very knowledgeable about the Coastal Plans myself, but wonder if anyone else is up to speed that can shed some light?

Would be a shame to not be able to drop FAD's in the future, given global warming and all... Also, as a diver and spearfisher, we probably should extend the discussion to include artificial reefs.

Anyone know if the BGFC or NZRFC have made submissions in this respect?

I have alerted Paul Batten (NZBGFC Zone 2 Rep and involved with the Northland Coastal Plans discussions) to participate in this thread...he will hopefully be able to keep us all one step ahead of proceedings!

FYI - I am on the management committee of the NZBGFC (Public Relations Officer), so any q's about the NZBGFC can be directed to me and if I don't know the answer I will endevour to do so and report back...

"We are going to learn a lot more on Sunday, the brief is; minister of Fisheries put a 2 year moratorium on aquaculture permits to stop the fast
higgledy piggely rush and allowcation.
Local/regional councils have 2 years to consult with who ever to ascertain where aquaculture could be allowed and where it can not go. There is around
180+ applications for new aquaculture permits held up by this process, and some applications are for over 500 hectares of open ocean that we will be
excluded from. The northern regional council has started first with a discussion doc. That I have one copy per club and a seminar next week that I'll attend. They are also looking at a coastal occupation levi/charge, like far north district council pay an annual fee to use public launch ramps!!"

Will keep you all posted as to outcomes....I also have the submission document in wrod format if any wants a copy let me know!!

OK, then could someone fill us in on when and where and how we can make a submission. I presume the issues are:

1. Ensuring the definitions of the coastal plans list FAD's and artificial reefs for recreational (and possibly even commercial) use. I guess this discussion also should include placing any structure underwater - including wrecks (is there already a process for them?)

3. Including and classifying such structures as an activity (I dunno much about coastal plans, but presumably as a controlled activity) in some areas and a non-complying in others, maybe a permitted activity in some places seen as ideal for deployment of such structures.

5. Rules for protection of the structure (ie, minimum distance sway from fishing nets etc), managing who can use it (private/public rights issue), what activities are approrpriate around it (ie, fishing/no fishing, diving, reserve, scientific, commercial FAD, etc), who owns it, and who has the right to alter/remove it.

It is true that our fishing grounds are being reduced, that FAD's and artificial reefs and wrecks work well to augment fishing, diving, and even scientific activities. We need to ensure a process is in place for future unknown opportunities which may arise in this respect.

All this will of course depend on what stage the coastal plans are at - where is a draft we can view (online?) and are we in time?

Hmm, I've had a look at the NRC website now, and I'm a bit clearer about what they are seeking. Fortunately, I am actually an expert in the area of public leasehold land. Here are my initial thoughts...

NRC has asked where should marine farms go and not go. Obvious concerns are raised and obvious exclusions are raised. Everyone can have input on that by submitting on that. We will need an objective test as to what is too much seabed to be covered in particular areas (ie, a percentage of enclosed harbour waters I guess). In the face of high demand, low supply and full economic pricing of the resources being offered (seabed) will reduce the level of actual marine farms.

The next question is how much should the marine farmers pay? The farmers are taking control of public land for private benefit. In the past, similar issues have been dealt with by the local authority issuing seabed or foreshore licences. Terms are usually quite standard, for defined terms with renewal periods (often 21, 50, 80 years etc), with a commencement licence fee and periodic licence fee reviews. Reviews are undertaken by valuers in much the same way as ground rents (my particular specialty). These permits or licences relate to marinas, reclamations, wharves, mooring areas, slipways, etc. The marine farms are no different whatsoever. Terms are similar sometimes to the Public Bodies Leases Act or other standard licence agreements. If the NRC does not follow a similar lease/licence structure, there is serious question over their competence at handling such an issue. Subsidies to encourage the industry should be a separate issue if that is what HRC wishes to do.

Should they elect not to charge a market related licence fee, they are underselling the common estate, and we should all - every one of us, make an application for as many sites as we can, because the NRC will be transferring wealth from the public to the licence holders (in this case private fishing companies who have in the past been given free allocations).

The issue I will make submissions on is my own professional observation that such licences (and indeed all leases issued under the public bodies leases act 1969) do transfer wealth to the private sector, as the licence tenure has value and is in fully tradable. That value is seldom fully captured when issuing a new licence at a 'market licence fee'. If new licences are agreed now, they will be trading at significant premiums in a short time (witness fish quotas). This is wealth that is transferred to the fishing companies, created by subdividing the public estate. To avoid this situation, to ensure the NRC receives full benefit of the licences now and in the future, to avoid transferring wealth to the fishing companies from the public, and to maximise the return on the public estate, I suggest the following system:

1. NEW licences be publicly auctioned at an annual licence fee. The sale of licences should be distinct from the resource consent process. True competition to be ensured in the process.

2. Licence fees to be reviewed periodically (normally say 5 yearly) to a market level, taking into account the full economic value of the licences and with specific guidance as to considerations to be taken into account (ie, evidence of value over and above the improvements value and licence fee payments). This is similar to the rent review process well established in all commercial property and leasehold portfolios, and is relatively efficient at maximising economic benefit. It is crucial that directives include a reference to amortising capital payments for existing licences, so NRC captures the maximum benefit. I have some additional specifications which will capture the best result for NRC.

3. Licences to be for a defined term such as 20 years to provide certainty of tenure, with several rights of renewal up to a maximum of say 80 years combined terms. At the end of each term, the licence fee is to be auctioned again, and the sitting licence holder can bid. If someone else bids higher, an assessment of the economic value of the remaining improvements (if any) to be paid to the outgoing licence holder. Provision to be made for NRC cancellation of licences with full compensation to licence holders.

4. An alternative would be for typical market related rent reviews, but if the licence is transferred, and every time it comes up for renewal, the premium attributable to the value of the licence should be transferred back to NRC, less an allowance for the former licence holder's improvements. (My concern is that the full economic value of licences and leases is not currently captured by the licence fee process).

5. EXISTING licences - it is ironic that we face another fishery allocation issue! The sitting licence holders must be given an opportunity to bid a rent on their sites and paid out for their improvements if they do not outbid all comers. Some concession may be required, however and this can be discussed further (previous examples of transitional arrangements such as fee reductions, stepped changes etc assist transition).

6. A responsible portfolio manager (as NRC should aim to be) would exploit the scarcity of the seabed locations, and not flood the market with licences all at once. Zoning to reduce permissible areas is one way to do this, commercial acumen when negotiating licences is another. The number of applications will certainly reduce if applicants are forced to pay for what they are getting, and pay the full price. Professional specialist management of the portfolio of seabed licences must be run properly, and NRC must ensure it has that expertise.

7. What I have proposed is a totally market-led solution, where NRC receives full economic benefits from issuing seabed licences for aquaculture. The farmers cannot complain they are being charged too much because if they don't pay that, someone else will. This system is similar to what has happened in the past, but is provides an improvement over the outdated public leases and licences which were issued by councils in the past.

Please take these comments ingto account if you are making submissions yourselves.

Whao!....some intense stuff in there Reidfish!...all very good indeed...who said holding ya breath for extended periods decreases the ol' brain cells??...perhaps you should get involved in a greater capacity than just "another" person submitting their concerns....

Hmm, the plot thickens. NZ Underwater advises ARC is doing the same thing, and that their 'consultation' is essentially finished - ie, they have talked to the aquaculture people. Nice. The Aquaculture council is apparenntly considering handing out compensation to commercial fishers for lost fishing grounds or something. Really nice. I'm trying to get to the bottom of that - details of proposed changes on:

if you want to get in contact with me i have the docs to make submissions on these matters, although it would appear that it will not matter what submissions are made, if they want to push ahead they will do just that. Point in question the kingfish farm at whangarei heads. objections far outweighed those in favour but it is still going ahead, and now looks like it will be going into foreign ownership. can we afford to loose these large chunks of our accessable coastline ?

Maate, I think we probably need to recognise that it's better to give up a bit more coastline and have them catch less of the old green-backs from the sea, don't you? Fact is it will be more efficient to farm them, and fishing will become a thing of the past. I really won't mind if a few fish farm nets are spread around the coast, poor fullas might need the odd liberation effort, but also might find a few get released like snapper from the farm at Kawau. Long as it doesn't take up too many spots is the issue. We do need to recognise the economic benefits, especially in the far north. What if the money they paid for their licence fees went towards buying back quota or prioviding better boat ramps? Northland Regional council is asking the public what to do with the money. They are also wasking where shoudl the AMA not go. This is your chancve to participate.

I am working on getting maps e-mailed out to all dive clubs and shops and divers, and will arrange same thing for fisho's if you want when we have it sorted. This forum is good for that sort of thing. Then we can mark out where we use the coast and the AMA go in areas not so important to us. Sounds fair. In Auckland, it seems the AMA are only in existing harbour areas where there already are farms. The areas I think are actually too restrictive.

IT CONCERNS ME WHEN PEOPLE MAKE STATEMENTS THAT ARE NOT IN ANY WAY CORRECT.

THE COMPANY WHO WILL CARRY OUT THE AQUACULTURE FARM AT WHANGARIE HEADS IS 100 % NEW ZEALAND OWNED AND HAS CARRIED OUT EXTENSIVE RESEARCH INTO KINGFISH/SNAPPER/CRAYFISH OVER THE LAST 5 YEARS AT A CONSIDERABLE COST.THIS COMPANY HAS RELEASE MANY THOUSANDS OF FISH TO THE WILD.

IF THE RECREATIONAL FISHER COULD UNDERSTAND ENHANCEMENT TO THE WILD STOCK IS PART OF THE OVERALL PLAN.

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